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Currently banks and mobile network operators (MNOs) execute agreements to ensure network coverage and agents reach for the service.The audit and governance scope of mobile banking in Bangladesh mainly focus on adherence to the policy established by the guidelines.
Banks have to follow the full KYC policy issued by Anti Money Laundering Department (AMLD) of Bangladesh Bank for the cash points/agents/partners.All transactions should be monitored through an IT-based system developed by the banks.Banks shall ensure that suspected transactions can be isolated for subsequent investigation.Banks need to ensure that these limits and caps are built into the mobile banking platform and service charge rules are set up as per the policy.Periodic audit is needed to ensure that this continues to be properly applied.Additionally as practitioners we continue to learn about governance and audit and determine the best ways for responsibilities to work across partners.
By reflecting on these there may be useful points for others in Bangladesh as well as for other bank-based branchless banking developments in India, Nigeria and elsewhere around the world.
This means at any point in time, reconciliation processes must be in place to allow the following to be checked: Bank Balance = Channel Balance (Agent Wallet Balance Distributor Wallet Balance) Bank Branch Wallet Balance (If Banks deploy their own Branch to work as channel for Mobile Banking) ATM Wallet Balance (If Banks deploy their own ATM channel to work as channel for Mobile Banking) Registered Customer Wallet Balance Merchant Point Wallet Balance Commission Wallet Balance.
If a Bank disburses commission related to mobile banking through the mobile banking platform, it must keep an equal amount of funds in the account.
Banks have to use the prescribed ‘Know Your Customer (KYC)' format as given in the MFS guidelines.
The Bank will be responsible to ensure that KYC processes implement guidelines issued by Anti Money Laundering Department of Bangladesh Bank (AMLD) for all customers and across all agents and partners.
All virtual points created in the economy must be backed by the balance kept in the Bank.